IR 05000382/1990018

Insp Rept 50-382/90-18 on 901029-1102.No Violations Noted. Major Areas Inspected:Quality Verfication Function,Including Internal Audit Function,Activities of Iseg & Actions on Previously Identified Insp Items

ML20062H410
Person / Time
Site:	Waterford
Issue date:	11/15/1990
From:	Barnes I, Ellershaw L, Gilbert L, Mcneill W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20062H395	List: IR 05000382/1990018 ML20062H394
References
50-382-90-18, NUDOCS 9012040301
Download: ML20062H410 (10)

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APPENDIX I

U.S. NUCLEAR REGULATORY COMMISSION l

REGION IV

NRC Inspection Report: 50-382/90-18 Operating License: HPF-38 l Docket: 50-382 Licensee: Entergy Operations, In P.O. Box B Killona, Louisiana 70066 Facility Name: -WaterfordSteamElectricStation, Unit 3(W3SES)

Inspection At: W3SES site, Taft, Louisiana

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Inspection Conducted:- October 29 through November 2, 1990 Inspectors: I' 8% / / - /.r - f o -

[L. E. Ellershaw, Reactor Inspector, flaterials Dat and Quality Programs Section, Division of Reactor Safet Om //-/r- 9 0 '

[ lL. D. Gilbert, Reactor Inspector, Materials Date

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and Quality Programs Section, Division of

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Reactor Safety WSw

[ W. M. NcNeill, Reactor Inspector, Materials-ll-tr-90 Date

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and Quality Programs Section, Division of Reactor Safety Approved: 3%

1. Barnes, Chief, Naterials and Quality

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Programs Section, Division of Reactor Safety 4012040301 901115 gDR ADOCK 050 g 2-

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. Inspection Summary Inspection Conducted October 29 through November 2, 1990 (Report 50-382/90-18)

Areas Inspected: Routine, unannounced inspection of the licensee's quality verification function, including the internal audit program and activities of the Independent Safety Engineering Group (ISEG), actions on a previously identified inspection finding, and followup to a 10 CFR Part 21 report and an identified pressure transmitter bolting proble Results: _ Within the areas inspected, nc violations or deviations were identifie The program criteria applicable to the quality verification function appeared

- to be sound and were being effectively implemented. The licensee has adequately developed and satisfactorily implemented a quality assurance program related to audits of onsite activities which is in conformance with Technical Specifications (TS) and commitments in the Final Safety Analysis Report. The licensee has recognized that their audits placed 1-ittle emphasis on observation

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of- work activities; thus, a new surveillance procedure was developed and

- recently issued. The procedure-is designed to enhance the audit program by requiring observations of work activities in order to assess the performance of

the work.' An inspector followup item (paragraph 5.3) was identified with

- respect to reviewing implementation of the new surveillance program at a later date. The ISEG appeared to be functioning in accordance with the requirements of the 1 Review of actions taken in regard to a 10 CFR Part 21 report concerning an l: identified quench crack in SA-193 grade B7 bar stock showed that the licensee

had appropriotely evaluated and resolved the issue. It was noted, however, that the engineering evaluation was not performed in a timely manner.

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,- DETAILS PERSONS CONTACTED

{ Enteroy Operations. In * R. G. Azzarello, Director, Engincering and Construction

D. E. Baker, Director, Operations Support and Assessments

' * R.,F. Burski, Director, Nuclear Safety J. D. Comeaux, Senior Engineer, Event Analysis Reporting & Response (EAR &R)

• M. Davis, EAR &R ttanager W. E. Day, Trending, Compliance & Response Supervisor

• G. D. Espenan, Engineer S. Ghanavati, Availability Engineering Supervisor

• G. Koehler, Quality. Assurance (QA) Support Supervisor

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J. Lanci, Work Authorization Closing Coordinato ~ * L. W. Laughlin, Licensing Manager B. R. Lee, Radiation Control Unit Manager

• A. S. Lockhart, QA Manager

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. J. M. Mahoney, Database Maintenance Engineer D, E. Marpc, Staff Engineer

. K. B. McArthur, Design Engineering Support Superintendent

• J. D. Morgan, QA Engineer

• R. J. Pollack,-QA Operations Supervisor

• P. V. Prasankumar, Technical Services Manager

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• R.-S. Starkey, Operations Supervisor P. E. Troy, Independent Safety Engineering Group (ISEG) Manager

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• H.;G. Waldschmidt, ISEG Engineer K. T. Walsh, EAR &R Supervisor

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• S. Butler, Resident Inspector

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.*Denotes those present at the exit meeting on November 2, 1990.

E s The inspectors also contacted other licensee personnel during this inspectio . ACTION 0N PREVIOUSLY IKNTIFIED INSPECTION FINDlHGS (92701)

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(Closed) Unresolved-Item (382/8930-03): Procurement of gas tungsten arc

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welding filler material.

L r The inspectors reviewed a listing of W3SES welding filler material purchase orders and welding procedure specifications (WPSs) in regard to conformance cf preheatandinterpasstemperatures(usedintheweldingoffillermaterial

_ qualification test coupons) with the requirements of the WPSs. The qualificttion test coupons were noted to have been welded using preheat

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-4-temperature which exceeded the miniraum specified value of the WPSs and interpass temperatures which were below the maximum specified value of the WPSs. This unresolved item was discussed subsequent to the inspection with an NRC representative on the ASME Section 111 Code Subgroup on Fabrication and Examination. it was determined from this discussion that the current wonding of NX-2431.1 in Section 111 of the ASME Code would not require welding of filler material qualification test coupons using the maximum interpass temperature value permitted by WPSs. This unresolved item is considered close . FOLLOWUP ON 10 CFR PART 21 REPORT (92700)

The inspectors reviewed the actions taken by the licensee in regard to a 10 CFR Part El report which was issued by PVN Steels concerning an identified quench crack in 1-3/4 inch, SA-193 grade B7 bar stock. The defect was identified by W3SES personnel during fabrication of a pipe hanger and initially documented on Condition Identification 25693. ProblemEvaluation/InformationRequest(PEIR)60943wes issued by maintenance to engineering to identify other uses of bar stock from the heat in question. The inspectors verified that an appropriate evaluation of prior usage of the raaterial had been performed and the only identified safety-related application (i.e., emergency diesel generator turbocharger support spacers) corrected by replacement. The inspectors did note that, while the licensee appropriately resolved the issue, the engineering evaluation of its impact was not timely. Specifically, the condition was initially identified on July 1,1988, but the engineering response to PElR 60943 was not approved until September 23, 198 . FOLLOWUP OH A PRESSURE TRANStilTTER BOLTING PROELEM (92701)

The inspectors followed up on a bolting material discrepancy identified by the licensee on October 26, 1990, and documented in Nonconforming Condition Identification (HCI) 271797. It was determined that the 5/16-inch mountirg bolts used to initially install safety-related ITT barton differential pressure transmitters during construction of W3SES were not the material grade recommended in the subsequently issued vendor manual. The licensee determined through engineering evaluation, as documented in Design Engineering Calculation EC-H90-065, Revision 0, that the seismic qualification of the safety-related components was not affected and that all components would function during normal and accident conditions. The engineering evaluation appeared to address adequately the various bolting and torquing conditions which could exist for the transmitters installed in the plant. However, to be consistent with the vendor manual, engineering recommended that all mounting bolts for the ITT Barton pressure transmitters be replaced with bolting which meets the requiremer' ' 'he vendor manual by the end of refueling outage 4, QUALITY VERIFICATION FUNCTION (35702)

The purpose of this inspection was to assess the effectiveness iee quality verification activities in identifying technical issues slems of safety significance and in following up to ensure that the issues ano problems are resolved in a timely manner. The inspectors examined the activities of

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'the Independent Safety Engineering Group (ISEG), the internal audit and surveillance program and its implementation, the methodology associated with the control of nonconforming conditions, and root cause analysis and trendin ;

5.1 LSEG E ,

The ISEG has been established to assess overall quality and safety of plant activities and to apprise upper management of significant concerns. The

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function, composition, responsibilities, authority, and records requirements are. delineated in Administrative Controls Section 6.2.3 of the W3SES Technical Specifications (TS). The inspectors reviewed the responsibilities and activities of this quality verification organization in order to assess its effectivenes Procedure OSAP-102, " Independent Safety Engineering Group," Revision 8, established-the organizational guidelines and referenced the implementing ISEC documents (listed in the Attachment to this report) which were reviewed by the inspector Section 6.2.3 of the W3SES TS requires the ISEG to be composed of at least five, dedicated, full-time engineers located onsite with each having a bachelor's degree in. engineering or relatad science and at least 2 years-professional level experience in his/t v +ield. The inspectors reviewed the ISEG's organizational structure and' identified the following information. The !?EG ,

l -- presently is comprised uf a canager and four engineers. Personnel records  !

substantiated that each person'is qualified to serve as a member of the ISE The ISEGJis responsible for maintaining surveillance of unit activities to provide independent verification that the activities are performed correctl In addition, the ISEG reviewed unit operating characteristics, NRC issuances, industry advisories, Licensee Event Reports (LER), and other sources of design and operating ~ experience information...As'a--result of these activities, the- 4 ISEG is required to make detsilsd recommendations.regarding means of improvin unit safety.,LThe TS requires' records'of the ISEG's. activities'to be prepared,- 2 maintainedio and forwarded to the Nuclear Operations Support and Assessment-Manager each calendar month. ~1t should be noted that due to organizational i

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changes,Mhe records' of the ISEG'r activities are ~actually' forwarded to the Director, Operations Support and Assessments'. . The inspectors requested.the'

- available records for activities performed.during calendar year 1990:in order

, to assess the ISEG's activitie It was learned that records consisted of surveillance and assessment reports and: recommendations. The monthly-status ,

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-report-of the ISEG's activities identified the surveillances and assessments performed, theTnumber of recommendations; and the number of hours expended. .It also contained aD11st ofiell procedures and documents reviewed, and included- ,

several general headings such as " Plant Tours," " Training (and) Safety Meetings,"

and'"Hiscella'neous'Research," all of which showed the number of expended hour ' * It wasLnoted that the ISEG had performed 32 surve111ances,-2 assessments, and

had made 14 recommendations for the year to date. Since Procedure 05AP-102

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states that no retention-of-documentation from reviews is specifically required and that.only documentation pertaining to the performance of a surveillance.or (

assessment should be retained, the scope and extent of the ISEG's other' activities  ;

could not be fully' ascertained, it did appear that the'ISEG was performing its

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I activities as described in the TS and implementing procedure ,

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5.2 Honconformina Conditions The inspectors reviewed the implementing procedures (listed in the Attachrrent to the report) of the nonconforming condition program in terms of the quality verification function and the identification of technical issues and problem Several mechanisms are used to identify and document problems and conditions which are adverse to quality and may impact the safe and reliable operation of the plant. Hardware problems are initially identified on Condition Identification (Cl) reports. Those that are evaluated to be significantly adverse to quality are statused as Nonconforming Condition Identification (NCl)

reports. Programmatic type problems are identified in Quality Notices (QNs).

Plant events, depending on significance, are identified in either Potentially ReportableEvent(PRE)reportsorinSignificantOccurrenceReports(50Rs).

Conditions which are deemed to be questionable, are evaluated by engineering through the use of a Problem Evaluation /Information Request (PEIR) form. With the exception of PEIRs, these mechanisms were subjected to a root cause analysis when established criteria for significance were satisfied. Plant activities were controlled by Work Authorizations (WAs). Corrective maintenance and preventive maintenance was performed under a Controlled Maintenance Work Authorization (CHWA) and a Repetitive Task Work Authorization (RTWA), respectivel The inspectors verified the completeness of the nonconformance program input data by having a computer search of the Station Information Management System (SlHS)

performed, which showed that all CPWAs had Cl reports associated with them. In addition, the inspectors reviewed a sample of 60 RTWAs, 20 PRES, 10 SORS, and 10 PEIRs, to determine if nonconforming conditions had been identified, and whether or not a Cl report had been written. No instances were observed in which a nonconforming condition should have been identified but was not, or where a Cl report had not been initiate Procedure N0P-005, " Corrective Action," Revision 3, established a requirement for a trend analysis -program and the issuance of quarterly. trend reports, the first of which covered the fourth quarter of 1989. The inspectors revicwed the three quarterly trend reports to date. They were found to be comprehensive and included such elements as indicators of plant performance, human performance errors, precursors, quality concerns, equipment performance, and failure trends-from the nuclear plant reliability data system and the component failure analysis report. . The human performance error trends were based on a review of NCls, QNs, PRES, SORS, and LERs. The precursor trend element was found to be a recently established informal program. 'There were two recently identified trends which would indicate that the trending program appeared to be capable of identifying problems and technical issues. One dealt with a problem regarding improper close out' activities of WAs which.resulted in a request being made of ISEG to conduct an investigation. The other dealt with the identification of degrading megger readings on a boric acid pump motor and a safety injection room cooler fan motor, necessitating increased monitoring of the motors and subsequent replacemen The inspectors observed and discussed with the licensee that Procedure N0P-5 did not establish requirements for a trend report executive summary or a tracking and cross reference system for adverse trends and followup item _ _ . _ _ _ _ _ _ _ _ _

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-7-5.3 Audit Program (40702 and 40704)

The objective of this inspection was to verify that the licensee has developed and implemented a quality assurance (QA) program relating to audits of activities that is in conformance with TS and commitments in the Final Safety Analysis Report (fSAR).

The inspectors discussed the QA program with QA management personnel and reviewed the QA program documents listed in Attachment to verify that administrative controls exist which provide measures to assure that audits are scheduled and ;

performed by independent and qualified f.ersonnel, including special expertisu when needed. The audit program appeared to be consistent with the requirunents of the TS and FSA To assess the implementation of the audit program, the inspectors reviewed the 2 year QA internal audit schedule that had been developed for 1990 and 199 The audit schedule was consistent with QAP-305 and was approved by the lluclear QA Manager and concurred with by the Safety Review Committee. The schedule included audits which encompassed the areas and frequencies specified in Section 6.5.2.8 of the TS and Section 17.2.18 of the FSAR. The quarterly notifications of audits included the audit subject, audit number, organizations '

to be audited, assignment of audit team leader, and scheduled audit date Also, the inspector witnessed the October monthly quality activity meeting that was held on October 30, 1990, with plant management for two preaudit and three postaudit conferences. Plant management was informed at this meeting that a corrective action /nonconformance audit of nuclear operations would be conducted

'during the period of October 30 through December 7, 1990 and a test control audit of plant staff would be conducted during October 30 through flovember 29, 1990. An audit plan had been prepared for each audit which statrd the scope and activities to be audited. Plant management was also informed of the audit results for the three audits which had been completed during the month of October. These audits were: Audit SA-90-017.1 (to evaluate implementation and maintenance of the

' Audit SA-90-02 an (primary coolantimplementation audit to evaluate leakage . sources outside monitoring of the basemat containment progra program), and Audit SA-90-032.1 (to evaluate implementation of the 10-year inservice inspection and testing programs). Plant management was responsive to the audit findings with respect to assessment of impact on plant status and assuring that audit findings were properly assigned to organizations for corrective actio The inspectors selected the audits listed in Attachment for review to ascertain adequacy of audit scope, audit content, audit checklist, distribution to management, followup actions, timeliness of reports and responses to audit findings, and audit personnei qualifications. Based on this review, the licensee is satisfactorily implementing the QA program. However, the inspector noted that the eudit of special processes primarily focused on program requirements with little emphasis on observation of work activities. The inspector was informed that a new surveillance procedure, QAP-111, had been developed and recently issued to enhance the audit program through the use of surveillance of activities by 0A personnel. The surveillances are to be

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. performed 1 to 3 months preceding each of the scheduled audits. The surveillance schedule for October, as supported by the surveillance log for 1990, confirmed that Qt was now supplementing scheduled audits with surveillances of act Nities. The inspector, however, expressed concern that certain activities, such as special processes, might not occur curing the I to 3 month period prior to the scheduled audit, in that they are activities which are usually performed during outages. Thus the scheduling of audits would require an awareness of the normal occurrence of certain ectivities in order to allow for the effective use of surveillances. Since the effective date of the new procedure was September 20, 1990, the effectiveness of the surveillance program will be reviewed at a later date as an inspector followup ite (382/9018 01) EXIT INTERVIEW An exit intuview was conducted on November 2,1990, with those personnel denoted in paragraph 1, in which the inspection findings were summarized. No information was presented to the inspectors that wat identified by the lictosee

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-2 Procedure UNT-6-015. " Identification. Evaluation, and Reporting Defects and Noncompliances Under 10 CFR 21," Revision Procedure UNT-6-016, " Root Cause Investigation and Analysis," Revision 0 Procedure UNT-6-018, ' Human Performance Trending Program," Revision 0 Procedure UNT-7-025, " Plant Trending Program " Revision Procedure MD-01-16 " Failure & Trend Analysis," Revision Procedure PE-002-005, " Engineering Work Authorization Processing," Revision 11 Procedure OSAP-102, " Independent Saf ety Engineering Group," Revision 8 Procedure 05AP-104, " Assessments And Surve111ances," Revision 5 ,

' Procedure OSAP-109, " Corrective Action " Revision 3 AUDIT rep 0RTS, Audit Report SA-90-010.1, " Control of Special Processes." This audit was conducted from February 23 through May 4, 1990, and the report was issued on May 24, 199 Audit Report SA-88-010.1, " Control of Special Processes." This audit was conducted from February 19 through March 18, 198 Audit Report SA 89-032.1, "Intervice Inspection Program." This audit was conducted from March 29 through June 14, 1989, and the report was issued on July 13, 1989, i Audit Report SA-87-032.1, " Inservice Inspection Program." This audit was conducted from Apil 27 through July 7,198 Audit Report SA-89-022.1, " Radiological Environmental Monitoring /Off-Site Dose !

Calculation Manual." This audit was conducted from January 30 through March 3, 1989, and the report was issued on Merch 17, 198 '

Audit Report SA-90-022.1, " Radiological Environmental Monitoring /Off-Site Dose Calculation Manual." This audit was conducted from January 29 through March 15, 1990, and the report was issued on April 9, 199 Audit Report SA-88-022.1, " Radiological Environmental Monitoring /Off-Site Dose Calculation Manual." This audit was conducted from January 20 through February 22,198 Audit Report SA-90-004.1, " Corrective Action /Nonconformance." This audit was conducted from April 23 through June 14, 1990, i

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Audit Report SA-89-004.2. " Corrective Action /Nonconformance." This audit was  !

conducted from October 26 through January 11, 199 '

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Audit Report SA-88-005.1 " Organization t, OA Program." This audit was conducted from Fovember 21, 1988, through February 10,1989,' and the rerort was ,

issuao on March 9, 198 ;

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